Skip to content This library is free, offered as dana. If it helps your work, donate here →

This is one of 3,622 free prompts in the penguin tree ai library. Sign up once and the whole library opens, with new prompts by email.

open the library →

AML red flag identifier

Screens transaction data and account activity against FATF and FinCEN money laundering typologies, flagging suspicious behaviors across 8 red flag categories with severity ratings, typology citations, and SAR-readiness…

download .md

Purpose

Scan transaction and account data against established FATF and FinCEN red flag typologies to surface suspicious activity indicators, rank them by severity, and produce a SAR-readiness assessment — turning raw transaction review into a structured, defensible investigation record.

When to Use

Invoke this skill when the user asks to:

  • Review a customer's transaction history for suspicious patterns
  • Triage or investigate a monitoring system alert (structuring, velocity, geographic risk)
  • Screen virtual asset transfers for mixing, chain-hopping, or peel chain behavior
  • Assess whether observed activity meets the threshold for a SAR filing
  • Identify which FATF or FinCEN typology a given behavior maps to
  • Prepare the factual basis for a SAR narrative from transaction data

Inputs Required

Before starting, collect:

  • Transaction data: Dates, amounts, direction, counterparties, and instrument type (fiat wire, ACH, on-chain transfer, card, cash)
  • Account context: Account type, customer risk rating, KYC/CDD profile, expected activity, account age
  • Customer profile: Occupation/business type, stated source of funds, jurisdiction of residence
  • Institution type: Crypto firm / broker-dealer / bank / MSB (determines applicable typologies)
  • Time window: The review period being examined
  • Prior alerts or filings: Any earlier SARs, CTRs, or dispositioned alerts on this customer
  • Counterparty intelligence: Any known exchange, mixer, sanctioned entity, or high-risk jurisdiction exposure

If customer profile or expected activity is missing, note the gap explicitly — deviation from expected activity is a core detection signal and its absence limits certainty.

Instructions

Screen Activity Across 8 Red Flag Categories

For each red flag detected, record:

  • The specific observed behavior (with amounts, dates, counterparties)
  • Typology source: FATF Virtual Assets Red Flag Indicators (2020), FinCEN Advisory reference, or BSA structuring rule
  • Severity: Low / Medium / High / Critical
  • Corroboration needed: What additional data would confirm or clear the flag

Category 1 — Structuring & Threshold Avoidance Transactions patterned to evade reporting thresholds.

  • Multiple transactions just below $10,000 (CTR) or $3,000 (recordkeeping) thresholds
  • Cash or crypto deposits broken into rounds across days or accounts
  • Deposits followed by rapid withdrawal at similar sub-threshold amounts
  • FinCEN reference: 31 CFR 1010.314; FATF layering indicators

Category 2 — Rapid Movement & Velocity (Layering) Funds moving through accounts with no economic purpose.

  • Pass-through activity: funds in and out within 24–72 hours, minimal residual balance
  • High transaction velocity inconsistent with customer profile
  • Chain-hopping across multiple virtual assets to obscure trail
  • Peel chains: large amount split into many small hops to a destination
  • FATF reference: VA Red Flag Indicators — transaction patterns

Category 3 — Obfuscation & Anonymity-Enhancing Tools Deliberate concealment of source, destination, or ownership.

  • Use of mixers, tumblers, or coinjoin services
  • Privacy coins (Monero, Zcash) in otherwise transparent-asset activity
  • Transfers to/from unhosted wallets with no counterparty attribution
  • Use of nested exchanges or unregistered VASPs
  • FATF reference: obfuscation of source of funds indicators

Category 4 — Geographic & Jurisdictional Risk Exposure to high-risk or sanctioned geographies.

  • Counterparties in FATF grey/black-list jurisdictions
  • Activity involving OFAC-sanctioned regions or entities
  • IP/geolocation mismatch with stated residence
  • Funds routed through jurisdictions with no logical business nexus
  • FinCEN reference: geographic risk advisories; OFAC sanctions lists

Category 5 — Profile & Behavioral Anomalies Activity inconsistent with the known customer.

  • Volume or transaction size far exceeding expected activity per KYC
  • Sudden account activation after dormancy
  • Occupation/income inconsistent with transaction scale
  • Reluctance to provide source-of-funds documentation
  • Third-party control indicators (single device/IP across multiple accounts)
  • FinCEN reference: unusual customer behavior advisories

Category 6 — Counterparty & Network Risk Suspicious relationships between accounts.

  • Funnel accounts: many senders → one aggregator → single withdrawal
  • Circular transaction flows returning funds to origin
  • Interaction with wallets/accounts previously linked to fraud, ransomware, or darknet markets
  • Newly created counterparties with immediate high-value activity
  • FATF reference: transaction network typologies

Category 7 — Fraud, Scam & Illicit-Proceeds Indicators Signals of underlying predicate crime.

  • Deposit patterns consistent with pig-butchering / romance scam victim flows
  • Ransomware payment patterns (large one-time to known extortion clusters)
  • Elder financial exploitation indicators
  • Business email compromise (BEC) redirect patterns
  • FinCEN reference: relevant fraud advisories and BEC alerts

Category 8 — Sanctions & Evasion Attempts to circumvent sanctions or embargoes.

  • Transactions to/from OFAC SDN-linked addresses
  • Value transfer patterns consistent with sanctions evasion (frequent small VA transfers to embargoed regions)
  • Use of front entities or shell counterparties
  • FinCEN reference: OFAC compliance advisories

After Screening: Consolidate the Findings

  1. Rank all flags by severity — Critical and High first.
  2. Identify typology clusters — where multiple flags reinforce a single scheme (e.g., structuring + velocity + funnel account = classic layering operation), state the composite typology explicitly.
  3. SAR-readiness assessment — for the overall pattern, assign one disposition: - File SAR — activity meets the "known or suspected" standard; state the two or three strongest supporting flags - Investigate further — indicators present but corroboration needed; list the specific data to pull - Clear/Monitor — flags explained by profile or documentation; note the rationale
  4. Draft the factual basis — 3–5 sentence neutral, chronological summary of the who/what/when/where/how much suitable for a SAR narrative. State facts only, no speculation or legal conclusions.

Output Format

  • Structure: Findings grouped by category (only categories with hits shown), each flag with severity + typology citation; followed by consolidated ranking, typology cluster analysis, SAR-readiness disposition, and factual-basis draft
  • Length: 700–1,100 words depending on flag count
  • Format: Structured document — flag findings as labeled bullets, severity ranking as a table, factual basis as prose
  • Sections: Detected Red Flags (by category) → Severity Ranking Table → Typology Cluster Analysis → SAR-Readiness Disposition → Factual Basis Draft
  • Tone: Investigative and neutral — precise, evidence-anchored, no editorializing; the tone of an examination-ready workpaper

Quality Checklist

Before delivering output, verify:

  • [ ] Every flagged behavior cites a specific FATF or FinCEN typology source — not a generic "suspicious" label
  • [ ] Each flag has a severity rating (Low/Medium/High/Critical)
  • [ ] The severity ranking table orders flags Critical → Low
  • [ ] Typology cluster analysis names the composite scheme where flags reinforce each other
  • [ ] SAR-readiness disposition is a single clear call (File / Investigate / Clear) with named supporting flags
  • [ ] Factual basis draft contains only stated facts — no legal conclusions or speculation about guilt

Notes

  • This skill supports, not replaces, human analyst judgment and institutional SAR-filing procedures — final filing decisions rest with the compliance team.
  • The strongest cases are typology clusters, not single flags; one threshold-adjacent transaction rarely warrants a filing, but structuring + velocity + geographic risk together often do.
  • When customer profile data is thin, deviation-from-expected-activity flags carry less weight — flag the KYC gap itself as a finding.
  • Keep the factual basis strictly descriptive; SAR narratives are undermined by conclusory language like "the customer laundered funds."

How to use this skill

This file is a Claude Code skill in Anthropic's standard format — markdown with YAML frontmatter at the top.

Installing in Claude Code:

  • ~/.claude/skills/<folder-name>/SKILL.md — auto-loads in every session anywhere on your machine (recommended for skills you'll use across multiple projects)
  • <your-project>/.claude/skills/<folder-name>/SKILL.md — auto-loads only when working in that project (recommended for project-specific skills)

Restart Claude Code or open a new session to register.

Using in Claude.ai, ChatGPT, Gemini, or other AI tools:

  1. Drag this file into a new chat, or copy and paste its contents
  2. Send your task or request as your next message — the AI will apply the skill where it fits

For Claude Code skill details: https://docs.anthropic.com/en/docs/claude-code/skills